Indigo by Moran is against the wishes of the community. The facilities and infrastructure on Ocean Street are not sufficient enough to provide for such a development. The already scarce parking on Ocen Street will be stretched further and will be worsened more so in the summer months. The development and increased traffic poses risks to residents and to the childcare centre on Lagoon street. The proposal jeopardises our already fragile local environment through the removal of trees and the site of Aboriginal Man, a site of Indigenous historical significance, will also be jeopardised. I am not opposed to the building of aged care facilities, however community input and voice should be at the forefront of planning in this way.

Kate Meaney
5/11/25
To: The Secretary DPHI, Indigo By Moran - 156 Ocean Street Narrabeen
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I am a long-term resident of the Northern Beaches Council area and I am writing to formally object to the proposed state-led project Indigo By Moran - 156 Ocean Street Narrabeen. As a resident who values our local environment, community character, and sustainable development, I am deeply concerned that this proposal is inconsistent with established planning principles and will have long-term negative impacts on both the local community and the surrounding natural environment.
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1. Unsuitability
The proposed development is inconsistent with the Northern Beaches Local Environmental Plan (LEP) 2011 and the NSW Planning Policy framework, which emphasise that development should be compatible with the existing character, scale, and amenity of the surrounding residential area.
Narrabeen is primarily a low- to medium-density residential suburb, and inserting a large-scale, high-density luxury apartment complex will significantly disrupt the existing built form and visual landscape. The Environmental Planning and Assessment Act 1979 (EP&A Act) requires that development demonstrate ecological sustainability and social cohesion. The scale and bulk of this project are inconsistent with those principles.
The State Environmental Planning Policy (Housing) 2021 (SEPP (Housing) encourages diverse and affordable housing outcomes, not concentrated luxury developments that provide little to no community benefit. This proposal appears to cater to a high-income demographic and fails to address the pressing need for affordable or key-worker housing in the Northern Beaches region.
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2. Parking Issues
Parking and traffic management in Narrabeen are already under strain, with Pittwater Road and Ocean Street experiencing congestion during peak hours. The Northern Beaches Transport Strategy highlights that sustainable development must not exacerbate traffic congestion or reduce local accessibility.
This project will increase on-street parking pressure, impede emergency vehicle access, and reduce pedestrian safety.
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3. Wildlife Concern
Narrabeen and its surrounding ecosystems form part of a coastal wildlife corridor that supports a range of native species, including birds, reptiles, and small mammals. The proposed site lies within proximity to sensitive ecosystems such as Narrabeen Lagoon Catchment and associated vegetation communities protected under the Biodiversity Conservation Act 2016 (NSW).
Clearing or fragmentation of habitat for large-scale construction will disrupt local fauna movement and breeding areas. Increased lighting, noise, and human activity from a high-density complex will also have ongoing ecological impacts.
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This proposed development is fundamentally unsuitable for its location. It conflicts with the intent of local planning instruments, fails to respond to the established character and infrastructure capacity of Narrabeen, and poses unacceptable risks to the local environment and wildlife.
I urge the Department to reject this proposal to ensure that any future development aligns with sustainable planning principles, the needs of the community, and the preservation of Narrabeen’s unique coastal character.

My wife and I attended a talk and have received documentation on the propose 'Indigo by Moran" project here in Narrabeen.
We support the project and have no objection to the development. It has been well thought out and will not be an eyesore to the area; in fact, it will be an improvement based on the surrounding buildings and in particular the building on the existing site. It will have four levels of accommodation, two levels of parking and a roof top area of recreational facilities. Buildings of this type - providing accommodation the those over 60 years of age - tend to be far and few apart on the Northern Beaches. If the project goes ahead in its current design, we will be looking to acquire an apartment.
Regards, Peter & Louise Edgley

I wish to formally object to the proposed development due to the size and scale, it's too large and too high and is in stark contrast to the exisiting buildings around it.

I am opposed to the acquisition and demolition of the existing houses for this project as they can provide homes for people in the area.

There is already a problem with parking in the area and making the development to this scale will affect the parking and traffic in the area.

For these reasons, I respectfully request that the Council refuse this application in its current form.

To all in charge of the proposed development Indigo - by Moran, 156 Ocean Street Narrabeen.

My unit is at 91 Lagoon Street, literally a few doors north of the proposed development, thankfully not next door to, adjacent to or opposite the development site. I have been living on Lagoon Street Narrabeen for just over 22 years now and love the local area, just as it is. Narrabeen is one of the few remaining beachfront areas that hasn't been devastated by highrise developments and should remain as such.

There are many reasons why I believe this development should not go ahead in its current design:
* Incompatibility with the local area - we currently have nothing above three levels - this would be an absolute eyesore, block sunshine, create wind tunnels, it just does not fit with the local environment.

* Increased traffic - over the last two years there have been many strategies explored by local government to reduce the traffic and minimise the flow of cars throughout this area of Narrabeen. A development of this scale will only add to the congestion and traffic flow. Squashing so many new residents in to these small streets will create incredible congestion!

* Lack of parking - parking is already an issue in this peninsula of Narrabeen, particularly through summer or whenever nippers or any surfing competitions are on. Parking is at a premium already, please don't reduce it for current residents even further! In terms of the proposed development plans - a measly 10 visitor parking spots is simply not enough!

* Safety - I chose to invest in the peninsula Narrabeen area to bring my young son up in an area away from highrise buildings and congestion, yet this development will be creating the complete opposite of that for our local area. The increased service vehicle traffic, let alone the increasing residential population of such an enormous development will create unsafe conditions for my son walking to and from school, to and from the local beach and lake. He will have to pass this development site and it's unsafe conditions to even walk to the local supermarket. There are so many young children living in this peninsula that will be directly impacted by being unable to walk safely on the street paths, particularly throughout the build time!

These are just the issues that directly relate to my family if this development were to go ahead. I am lucky not to be adjacent or directly opposite the site as the drawings do not accurately show the sun and shadow that will be created.

As for the poor residents at 83 Lagoon Street, being completely boxed in by the development, I am completely appalled! That poor family will be completely overshadowed and surrounded by a monstrosity over double the height of their two storey house, with setbacks that would devastate their privacy in their family home. Let alone imagining how this development will decimate their price value if they ever were to try and sell their property - the developers should truly be ashamed of themselves, so ridiculously money hungry. Let's be honest, this development is not for the benefit of our local community, it is for the development company to make money at the expense of our local residents.

PLEASE DO NOT ALLOW THIS DEVELOPMENT TO PROCEED IN ITS CURRENT DESIGN!

PROPOSAL: Construction of a new 5-storey seniors housing development (149 ILUs and 10 RCF rooms)

I object to SSDA SSD-76220734 for the proposed seniors housing development at Narrabeen on the grounds that the excessive scale, bulk, and complexity of the environmental risks are unacceptable, failing to mitigate adverse impacts on the locality and its residents, as demonstrated by the project’s own Environmental Impact Statement (EIS).

1. Gross Non-Compliance with Height Standard and Adverse Impact on Local Character
The proposed development fails to respond appropriately to the low-to-medium density residential character of the area, resulting in unacceptable bulk and scale.
• Excessive Height Breach: The maximum permissible building height is 12.3m, derived from the Warringah Local Environmental Plan 2011 (WLEP 2011) base height of 8.5m plus the 3.8m bonus permitted under Clause 87 of the Housing SEPP. The proposal seeks approval for a building height of 21.1m. This constitutes a variation of 8.8m or 71.5%. This monumental departure from the planning control is unreasonable and unnecessary, particularly given that the surrounding residential context is primarily characterized by single and two-storey dwelling houses, with maximum building heights generally limited to three or four storeys along Ocean Street. The significant height increase cannot be visually integrated into the existing character, undermining the principles of good design cited in the EIS.
• Insufficient Justification for Bulk: While the EIS claims the bulk is necessary for amenity and landscape integration (courtyard and pine tree retention), the ensuing 5-storey form (with 3 basements) results in a Gross Floor Area (GFA) of 22,131m², substantially intensifying the residential use beyond what the locality can reasonably absorb without adverse impacts.

2. Unacceptable Environmental and Geotechnical Risk
The sheer scale of excavation required for this project introduces unacceptable risks related to ground stability, water management, and contamination.
• Deep Excavation and Groundwater Risk: The proposal requires bulk excavation to a depth of 10.9m below natural ground level to accommodate the three basement levels. The Geotechnical Investigation confirms that this excavation will intercept permanent groundwater within the marine sand profile, requiring dewatering. Furthermore, the site is located within a Class 4 acid sulfate risk zone. Excavation and dewatering on this scale carry a high risk of adverse impacts, including structural distress to neighbouring structures, soil erosion, and potential settlement of foundations if not perfectly managed.
• Contamination and Remediation: The Detailed Site Investigation (DSI) confirmed the presence of Asbestos Containing Material (PACM), asbestos-impacted fill, and lead-impacted soil on site. While a Remedial Action Plan (RAP) is prepared, the EIS confirms that additional work is needed following demolition to address "data gaps" and better delineate the contamination. This suggests the full extent of the complex remediation required, coupled with the deep excavation and dewatering in a Class 4 acid sulfate zone, is not fully confirmed pre-approval, elevating the risk to workers, the surrounding community, and the natural environment (South Creek / Narrabeen Lagoon).

3. Failure to Protect Aboriginal Cultural Heritage
The proposed 10.9m deep excavation poses a direct and significant threat to registered Aboriginal heritage in the immediate vicinity.
• Proximity to Burial Site: The site is located approximately 30m north of the registered AHIMS site 45-6-2747, a 4,000-year-old Aboriginal burial site.
• Risk from Excavation: The Aboriginal Cultural Heritage Assessment Report (ACHAR) explicitly identifies that the excavation of the proposed basement could have a significant impact on potential Aboriginal archaeological resources. While mitigation measures are proposed (such as further archaeological excavation and approval), the risk of serious and irreversible harm to significant heritage, compounded by the proximity and the extreme depth of the required works, weighs heavily against the suitability of the proposal in its current form.

4. Poor Internal Amenity for Vulnerable Residents
The design demonstrates a measurable failure to provide basic solar amenity to a significant portion of the seniors housing units.
• No Solar Access for 22 Units: Despite the stated compliance with the Apartment Design Guide (ADG) overall, the EIS confirms that 22 Independent Living Units (ILUs)—15% of the total proposed units—will receive no direct sunlight between the hours of 9 am and 3 pm during the winter solstice. For seniors living, a vulnerable demographic whose health and wellbeing is significantly supported by access to sunlight and heat, approving units with zero solar access represents a deficiency in environmental amenity that must be rejected.

5. Adverse Impacts on Local Infrastructure and Environment
The cumulative construction and operational impacts are inadequately mitigated and impose unreasonable burdens on the public domain.
• Traffic Generation and Public Transport Disruption: The development is anticipated to generate 25 vehicle trips per hour (vtph) during the PM peak period, which the Traffic Impact Assessment (TIA) notes is higher than the average for Seniors Housing. To accommodate the development's operational needs and improve safety, the proposal requires the relocation of the bus stop at the corner of Ocean Street and Octavia Street. This significant intervention demonstrates that the development's intensity immediately strains existing public transport infrastructure and requires the alteration of the public domain simply to enable the development to function.
• Mass Tree Removal: The emphasis on landscape design is contradictory to the requirement for the removal of 69 trees (including 24 considered significant) to facilitate the project. This massive loss of vegetation diminishes the ecological value of the site and conflicts with the objective to enhance urban tree canopy.

Request for Refusal:
Based on the cumulative and individual severity of the issues identified—specifically the massive height transgression of 71.5%, the unacceptable geotechnical/contamination risks associated with the 10.9m deep excavation in an acid sulfate zone, the proximity risk to the 4,000-year-old burial site, and the poor internal amenity for 15% of the future senior residents—the proposed development is not in the public interest.
I respectfully request that the application SSD-76220734 be refused.

Dear Minister / Delegate,

I write to object to the above-noted development application on behalf of myself (and my neighbours / community) and request that the application either be refused or significantly revised to address the serious concerns set out below.

1. Incompatibility with local scale, character & heritage

The proposal calls for the demolition of existing seniors housing and three adjacent dwellings, followed by construction of a 5- to 6-storey seniors living development comprising 149 independent living units, 10 residential care beds, and three basement levels of parking (192 spaces).
This scale, bulk and height is entirely out of proportion to the prevailing built form and character of the Narrabeen precinct. Local community groups have described it as an “over-development” of the site, dominating the skyline and overshadowing the beach-side suburb. 
Specifically:
• The height and massing exceed what the zoning and surrounding context can reasonably support, and as such fails the objectives of built form compatibility in local planning controls.
• The proposed development will obstruct views from neighbouring properties including those on the escarpment and from Collaroy plateau, and will have adverse visual impact. 
• Mature Norfolk Island pines and other vegetation feature prominently in the streetscape and heritage of the locality; removal or overshadowing of these features undermines the character and heritage value of the place. 

This projects claim that it is contributing to easing the housing crisis is false as the targeted demographic and expected price range of these units are unaffordable to those in need.

In summary, the proposal fails to demonstrate respect for the existing character, heritage and amenity of the surrounding neighbourhood, and thereby conflicts with the principle of ‘fit-for-place’ development required under the NSW Planning Framework.

2. Over-intensification and traffic / parking infrastructure pressure

With 149 units plus a 10-bed residential care facility, the scale of occupancy is substantial—and the proposed 192 car-spaces may not sufficiently address the cumulative traffic, parking and service demand.
Concerns include:
• Increased traffic congestion on Lagoon Street, Octavia Street and Ocean Street—noting that the site is one street back from the beach and access and egress will be constrained.
• Overspill parking into adjacent residential streets, especially given that the independent living units may belong to residents who still own vehicles and expect visitor parking.
• The local road network and public transport infrastructure are already under pressure; the additional burden of this development has not been satisfactorily justified. Community groups have flagged that local traffic and infrastructure cannot support further large-scale developments without significant upgrades. 
• The basement access off Lagoon Street means a concentration of vehicular movements in what is currently a low-density residential segment, potentially compromising pedestrian safety, particularly given proximity to the beach and local amenity.

Hence, the application fails to sufficiently demonstrate how the local infrastructure (roads, parking, pedestrian/cyclist amenity) will accommodate the increased demand without adverse impacts on neighbours and the broader public realm.

3. Environmental, landscape and biodiversity concerns

The site currently features mature vegetation, including Norfolk Island pines and other established trees which contribute significantly to the local landscape character and environmental amenity. The petition notes removal of “30 old 30 m Norfolk Island pines” among the concerns. 
Specific concerns include:
• Loss of habitat value and amenity provided by mature trees and landscaped grounds.
• Shadowing, loss of daylight and solar access to neighbouring properties due to the proposed height and massing.
• The site’s proximity to the coast and potential exposure to coastal hazards (sea-level rise, erosion, storm surge) may amplify risk. While the applicant may have addressed some hazard assessments, community concerns remain that the proposal does not adequately account for long-term climate change impacts.
• The high intensity of development and excavation for three levels of basement may impact groundwater, tree root zones, and local stormwater drainage; these impacts require rigorous assessment and mitigation, yet appear insufficiently addressed in the publicly available documents.

Given the environmental sensitivity of the site and immediate surrounds, the proposed scheme does not convincingly show that adverse environmental and landscape impacts have been avoided, mitigated or offset in accordance with the precautionary principle.

4. Community consultation, social merit and seniors housing need

While the applicant frames the project as meeting an “urgent need” for seniors living options on the Northern Beaches, concerns remain:
• The development offers 149 independent living units but only 10 aged care beds. Community members note that the former use on the site was a 55-bed aged care facility and 35 assisted living units—thus the proposal amounts to a reduction in long-term care capacity rather than a net increase. 
• There are serious concerns regarding the nature and depth of community consultation: residents claim that the “information sessions” ran by the applicant were more sales-orientated than genuine consultation, and that the short 14-day exhibition period is inadequate for a proposal of this scale. 
• A development may still meet a seniors housing need, but the negative externalities (bulk, privacy loss to neighbours, traffic, amenity impacts) must be weighed; in this case the community is of the view that the adverse impacts significantly outweigh the claimed social benefit.
• The proposal appears to be targeting the higher-end market (“luxury complex”) rather than addressing more affordable seniors housing need—raising questions as to whether the development qualifies as meeting a ‘community need’ or simply commercialising prime land. 

Therefore, from a social planning perspective, the application fails to satisfy the broader community benefit test, especially given the scale of the negative impacts imposed on the immediate neighbours and the public realm.

5. Precedent and strategic planning implications

Allowing a development of this bulk, scale and typology in this location sets a potentially damaging precedent for the Northern Beaches:
• If approved, it may encourage further similar large-scale seniors living developments in low-rise, beach-adjacent residential neighbourhoods, undermining the existing neighbourhood character and triggering ‘spot rezoning-like’ outcomes via the State Significant Development pathway.
• It could undermine local zoning integrity and the long-term strategic planning vision of the Northern Beaches, especially in areas that are not intended for high-density or high-rise development.
• Given the coastal setting and infrastructure constraints (transport, parking, public utilities), approvals of this nature may reduce flexibility for future planning by absorbing resident/visitor vehicle demand and infrastructure capacity currently aligned with lower density outcomes.

Hence, from a strategic planning standpoint, the proposal is inconsistent with achieving the right balance of growth, amenity and sustainability, and may lead to cumulative impacts that erode community confidence in planning fairness.

Conclusion & Requested Outcome

In light of the above, I respectfully request that the application for SSD-76220734 be refused unless substantial modifications are made to address the following minimum conditions:
1. A reduction in height, ceiling of 3 storeys, and reduction in bulk/scale so the building aligns with its neighbours and does not dominate the streetscape.
2. Significant increase in aged-care bed capacity relative to independent living units, so the social benefit is more clearly realised rather than appearing as a luxury retirement complex.
3. Expansion of infrastructure traffic/parking impact studies, including independent verification of local road/parking capacity, and robust mitigation measures (including resident vehicle caps, visitor parking controls, traffic calming, pedestrian/cyclist safety enhancements).
4. Preservation and integration of key mature trees (especially the Norfolk Island pines) and enhanced landscaping buffers to mitigate visual and environmental impacts; plus a detailed coastal hazard / climate adaptation analysis and appropriate mitigation.
5. Enhanced and genuine community consultation process (including extended exhibition period, additional community workshops, transparent Q&A on scale/height/amenity trade-offs) so that local residents have real opportunity to engage.
6. A commitment that the facility remains affordable and accessible (not purely top-end product) and that the development contributes to the broader housing supply for seniors (including lower-cost, moderated market units).

I trust that the Department will carefully weigh the documented adverse impacts of the proposal—on neighbourhood amenity, streetscape character, traffic/parking, environment and public infrastructure—against the claimed benefits, and will apply the test of “net community benefit”. At present, I submit, the proposal fails that test.

Thank you for your consideration. I would be grateful if you could advise me of the outcome of the assessment and any public hearing or further consultation process.

Yours sincerely

Subject: Objection to Proposed Development

Dear Council,

I strongly object to the proposed development as it is inconsistent with the established character, scale, and community feel of the surrounding area. This enormous proposal would dominate the landscape, overlook neighbouring homes, and diminish residents’ access to natural light and privacy. It would then set a president for other investors to do the same.

The development is out of keeping with the local environment and would further strain already limited parking, community facilities, and inadequate road infrastructure. Streets between Ocean and Lagoon are already congested and often function as single-lane due to parked cars, creating safety risks particularly during school hours and weekends. Additional residents, staff, and visitors would significantly worsen traffic congestion and road safety.

Parking is already scarce, with many residents forced to park several streets away. Increased demand will further reduce accessibility and safety for families, children, and pedestrians using local streets and public spaces.

Furthermore, Narrabeen lacks the infrastructure to support a large aged care facility. Public transport options are limited, and access to essential services and shops (such as Woolworths) is difficult for mobility-impaired residents.

This development does not reflect the community’s vision for a sustainable, liveable Narrabeen. A smaller, low-rise development designed with the area’s character and constraints in mind would be far more appropriate.

For these reasons, I respectfully request that the Council refuse this application.

Kind regards,
Phoebe Layden
Lagoon Street Resident

My husband and I are home owner residents in Narrabeen and we are writing to lodge an objection to the above large Development Proposal for 156 Ocean Street, Octavia and Lagoon Streets Narrabeen by developers Indigo by Moran. Our objection to this development proposal is based on the following points:

1. Size of Development:
The proposed six-storey apartment block is entirely inconsistent with the surrounding suburb, which consists predominantly of one and two-storey detached homes or three-storey unit blocks. A six-storey development in this area does not respect the existing character of the suburb – in particular the residential area that sits between Narrabeen Lake and the North Narrabeen - Narrabeen Beaches, where this development sits. The sheer scale of the development would have a significant and irreversible impact upon the community identity of the area.

2. Parking and Traffic Congestion:
The proposed development provides 192 car parking spaces (including only 7 visitor spaces) for a 149 x 2 and 3 bedroom luxury retirement apartment building (“An inspirational retirement lifestyle for Over-60s” as it is being advertised on local billboards). This is completely inadequate and will result in additional traffic and street parking from both residents, as well as visitors, along Lagoon and Ocean Streets – both of which are already significantly congested, particularly in Summer with people wanting to access the beach. This also does not take into account parking for staff or other service providers.
The previous Residential Aged Care facility at this site did not have a requirement for residents parking, as residents were incapable of driving (we have first-hand experience of this as my husband’s elderly mother was a resident of Wesley Taylor Village Aged Care home before it closed).

3. Environmental Impact:
Removal of the majority of existing trees from the property – some of which are large and have been there for decades – is completely inconsistent with environmental protection and the character of the suburb.

4. Setting a precedent that will forever change the local area:
The State Government has identified suitable high-rise precincts for the Northern Beaches Local Government Area (Balgowlah, Dee Why, Frenchs Forest, Manly, Manly Vale, Mona Vale and Brookvale) where developments of this scale align with the existing landscape and infrastructure. A six-storey luxury apartment complex on Ocean and Lagoon Streets in Narrabeen is not compatible with the surrounding residential environment. Extending high-rise developments into areas other than those identified by the State Government makes a mockery of the planned Town Centres concept.

5. Not addressing Aged Care or affordable housing:
The development is being advertised targeting a luxury lifestyle for Over 60s retirees. This does nothing to address the real needs of affordable housing for younger families and affordable Aged Care for the elderly.

6. Three-storey underground parking:
Based on where the development sits, this would likely be below current sea level. How will this impact local ground water and surrounding properties?

7. Lack of genuine community consultation:
A 14 day consultation period does not reflect a genuine desire by the developer to engage with the community which will be significantly impacted by this major development.

Please Note: This is not about “not in my backyard” – we understand buildings will be subject to redevelopment. However, a development proposal of this scale and magnitude is completely inconsistent with the existing neighbourhood, and would have a significant, detrimental, and unfair impact upon existing residents of the area. It is well outside the identified Northern Beaches Town Centre precincts, and is completely inconsistent with the present local environment and available infrastructure.

Yours sincerely,
Sandy & Don Foster
Narrabeen NSW 2101

Submission of Objection – SSD-76220734 (Indigo by Moran, 156 Ocean Street Narrabeen)

To: The Secretary, NSW Department of Planning, Housing and Infrastructure
From: Chris Jamieson, 145 Ocean Street, Narrabeen NSW 2101
Date: 4 November 2025
Re: State Significant Development – Indigo by Moran (SSD-76220734)

I am a resident and property owner at 145 Ocean Street, Narrabeen. I formally object to this application whilst acknowledging my support for well-designed seniors housing and appropriate development that benefits our community.

I support creating aged care opportunities for older Australians and recognise the economic benefits developments bring through construction jobs, ongoing employment, and increased patronage of local businesses. I also acknowledge Retirement By Moran's positive community contribution since acquiring the site, particularly their July 2024 partnership with the Northern Beaches Women's Shelter providing transitional accommodation for up to 90 women in crisis. This demonstrates Moran's capability to deliver development that serves both commercial objectives and community interests.

However, I object to the excessive scale of this proposal. This development will establish a precedent that fundamentally and permanently changes Narrabeen's character. Once approved, it cannot be undone. I advocate for better planning that achieves the worthy objectives of housing older Australians whilst remaining aligned with Narrabeen's established low-rise coastal character.

Key Objections

1. Excessive Height Departure (71.5%)
The permitted height is 12.3m (8.5m LEP + 3.8m Housing SEPP). The proposal seeks 21.1m, representing an 8.8m or 71.5% departure. This is excessive and unjustifiable. The proposal fails Housing SEPP Schedule 9 design principles for context, built form, and scale. The surrounding area comprises predominantly 1-3 storey dwellings. A 21.1m building is fundamentally incompatible with this low-rise coastal character.

2. Coastal Hazards and Deep Excavation Risks
Excavating 10.9m below ground level for three basement levels in a coastal flood-prone site adjacent to Narrabeen Lagoon breaches Coastal SEPP 2018 requirements. The EIS acknowledges groundwater will be encountered 2m above excavation level, requiring dewatering. This presents unacceptable risks: groundwater draw-down affecting neighbouring properties, saline intrusion, structural buoyancy issues, increased flooding vulnerability, and potential lagoon hydrology impacts. The site is within a Class 4 acid sulfate risk zone and Coastal Vulnerability Area. These risks are inadequately addressed.

3. Environmental and Design Deficiencies
The proposal demonstrates multiple failures: significant overshadowing of neighbouring properties; inadequate building separation creating privacy impacts; removal of 69 trees with only 54 replacement trees (net loss of 15); BASIX performance barely meeting minimum standards with no meaningful passive solar design, cross-ventilation, water reuse, or renewable energy beyond minimums; and insufficient deep soil landscaping. For a development of this scale, sustainability performance should exceed minimum thresholds, not barely meet them.

4. Traffic and Construction Impacts
The proposal includes 192 parking spaces requiring significant traffic movements on already constrained narrow streets (Ocean, Lagoon, and Octavia). Construction impacts will span 18-24+ months including prolonged noise, vibration, heavy vehicle movements for excavation spoil removal, dust, and disruption to local traffic and parking in a peaceful residential area.

5. Dangerous Precedent
This is the most critical issue. Approving a 21.1m building (71.5% above the standard) will signal to developers that similar scale is acceptable, triggering redevelopment applications along Ocean Street and the peninsula. This will transform Ocean Street from a low-rise coastal street into a corridor of multi-storey buildings. This transformation will be irreversible. Once buildings of this scale are constructed, they remain for generations. Future applications will cite this approval as justification. The community will lose the ability to maintain the character and amenity that make Narrabeen desirable.

6. Process and Governance Failures
No meaningful community consultation occurred prior to lodgement. The exhibition period (23 October to 5 November 2025) provides less than two weeks to review 40+ technical documents spanning hundreds of pages. A minimum four-week period is appropriate for State Significant Development. No Independent Design Review Panel assessment occurred despite the 71.5% height departure.

The Path Forward

I genuinely support high-quality seniors housing and the economic benefits development brings: construction jobs, ongoing employment for care staff, increased patronage of local businesses, rates revenue, and broader economic activity. These benefits can be achieved with appropriately scaled development. A redesigned proposal reducing height to 12-15 metres (vs. 21.1m proposed) could deliver viable seniors housing whilst maintaining neighbourhood compatibility and setting appropriate precedent.

This is not "all or nothing". It is entirely possible to achieve the legitimate objectives through better planning aligned with Narrabeen's coastal character. A building height of 12-15 metres would still deliver substantial seniors housing capacity whilst respecting the surrounding area.

Request

Under section 4.15 of the EP&A Act 1979, I respectfully request the Department:

1. Refuse SSD-76220734 due to: 71.5% excessive height departure; non-compliance with Housing SEPP design principles and Coastal SEPP provisions; inadequate coastal hazard assessment; unacceptable amenity impacts; failure to demonstrate sustainability beyond minimums; and setting inappropriate precedent that will permanently alter Narrabeen's coastal character.

OR

2. Require comprehensive redesign including: height reduction to 12-15m maximum; reduced excavation depth; improved sustainability exceeding minimum standards; retention of mature trees with net positive canopy outcomes; comprehensive coastal hazard management; Independent Design Review Panel assessment; and re-exhibition with four-week period and genuine community consultation.

Conclusion

I support well-designed seniors housing contributing to our community. I am not opposed to development at this site. I oppose overdevelopment out of scale with context that establishes damaging precedent for Narrabeen's future.
This proposal fails fundamental planning tests. A 71.5% height departure cannot be justified. Once approved, it opens the door to similar applications throughout the peninsula. The low-rise coastal character that makes Narrabeen valued will be lost.

A thoughtfully redesigned proposal can achieve the worthy objectives of providing seniors housing and supporting the local economy whilst respecting Narrabeen's character, complying with planning controls, and protecting coastal values.

I strongly urge the Department to refuse this application and work with the proponent to achieve a redesigned proposal that better serves both older Australians and the long-term interests of the Narrabeen community.

Note: Please refer to the attached comprehensive submission for detailed analysis, legislative references, and supporting evidence.